Frederick Douglas Abdullah - Page 13

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               Section 162(a) permits a deduction for the ordinary and                
          necessary expenses paid or incurred during the taxable year in              
          carrying on a trade or business.  The performance of services as            
          an employee constitutes a trade or business.  See sec. 1.162-               
          17(a), Income Tax Regs.  There must be a relationship between the           
          expenditures and the employment.  See Evans v. Commissioner, T.C.           
          Memo. 1974-267, affd. in part, revd. in part 557 F.2d 1095 (5th             
          Cir. 1977).  Expenses that are personal in nature are generally             
          not allowed as deductions.  Sec. 262(a).  A taxpayer is required            
          to maintain records sufficient to establish the amount of his               
          income and deductions.  Sec. 6001; sec. 1.6001-1(a), (e), Income            
          Tax Regs.  A taxpayer must substantiate his deductions by                   
          maintaining sufficient books and records to be entitled to a                
          deduction under section 162(a).  When a taxpayer establishes that           
          he has incurred a deductible expense but is unable to                       
          substantiate the exact amount, we are generally permitted to                
          estimate the deductible amount.  Cohan v. Commissioner, 39 F.2d             
          540, 543-544 (2d Cir. 1930).  We can estimate the amount of the             
          deductible expense only when the taxpayer provides evidence                 
          sufficient to establish a rational basis upon which the estimate            
          can be made.  Vanicek v. Commissioner, 85 T.C. 731, 743 (1985).             
               Section 274(d) supersedes the general rule of Cohan v.                 
          Commissioner, supra, and prohibits the Court from estimating the            
          taxpayer’s expenses with respect to certain items.  Sanford v.              






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